- 15 - petition in this case, petitioner made statements and requests and advanced contentions and arguments that the Court has found to be frivolous and/or groundless. In that petition and the supplement thereto, petitioner persists in advancing such frivo- lous and/or groundless statements, requests, contentions, and arguments. Consequently, even though we held in Keene v. Commis- sioner, 121 T.C. 8, 19 (2003), that section 7521(a)(1) requires the Appeals Office to allow a taxpayer to make an audio recording of an Appeals Office hearing held pursuant to section 6330(b), we conclude that (1) it is not necessary and will not be productive to remand this case to the Appeals Office for another hearing under sections 6320(b) and 6330(b) in order to allow petitioner to make such an audio recording, see Lunsford v. Commissioner, 117 T.C. 183, 189 (2001), and (2) it is not necessary or appro- priate to reject respondent’s determinations to proceed with the collection action as determined in the notice of determination and in the decision letter with respect to petitioner’s unpaid liability for 1994, petitioner’s unpaid liability for 1996, and petitioner’s respective unpaid liabilities for 1998 and 1999, see id.9 Based upon our examination of the entire record before us, 8(...continued) to respondent his request to make an audio recording of his hearing with the Appeals Office in advance of that hearing. 9See Kemper v. Commissioner, T.C. Memo. 2003-195.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011